Over the next two years, the UK’s Employment Rights Act (2025) will introduce the most significant changes to employment law in decades, with implementation already underway following Royal Assent in December 2025. Many of the reforms focus on worker protections, agency supply chains, union representation and strike action, and flexible labour models, which has led to understandable questions to the iGo Recruitment team from both employers and candidates.
This article is intended for healthcare employers and hiring managers who are facing questions and changes themselves, and clinicians considering their next move.
At iGo Recruitment, our value to hiring clients has seen increasing permanent healthcare recruitment and a backup of temporary staff, or temp-to-perm staffing. We work with clients to make long-term, high-quality appointments within health, government outsource, BPO and private sector service providers.
Current job titles in demand:
- Business Development (NHS & Government)
- RGN Nurse Band 5-7
- ADHD Assessor (Prescribing clinician)
- Specialist Nurse
- Project / Transformation manager
While permanent recruitment sits at the centre of what we do, we recognise that some organisations need short term temporary or interim support. iGo Recruitment support employers with temporary solutions compliant to the updated HMRC rules, to meet the business need of prompt time to hire or interim cover.
Why this matters
The Employment Rights Act is designed to improve fairness and predictability at work, raise standards across recruitment supply chains, and strengthen enforcement where organisations fall short.
For employers, this means greater scrutiny of recruitment partners and a stronger emphasis on compliance. For candidates, it brings clearer rights and improved protections, particularly where work is not permanent.
In regulated environments such as healthcare and government, specialist agencies with strong compliance frameworks such as iGo Recruitment have the processes, policies and procedures in place to meet or exceed requirements stipulated int he Employment Rights Act update, in time for the dates outlined below.
Employment Rights Act 2025 – Updated Timeline
2026 = compliance preparation year
April & October 2026 = enforcement + cost exposure
January 2027 = litigation and dismissal risk step‑change
2027 = structural reform of how work is organised
December 2025
At Royal Assent
Measures already in force
- Repeal of the Strikes (Minimum Service Levels) Act 2023
Meaning: Immediate rollback of prior strike restrictions
18 February 2026 (now live)
Trade union & industrial action reforms
- Repeal of the majority of the Trade Union Act 2016
- Removal of the 10‑year ballot requirement for political funds
- Simplified industrial action ballots and notices
- Protections against dismissal for taking industrial action
- Employees newly eligible for day‑one paternity leave and unpaid parental leave can give notice
Meaning: This is the first major “worker‑power” shift. Dismissal risk around industrial action increases and union processes are materially easier.
1 April 2026
- Repeal of the Certification Officer levy paid by trade unions and employer associations
Meaning: Administrative clean‑up, low direct employer impact.
⚠️ 6 April 2026 (major employer impact date)
Multiple substantive changes
- Collective redundancy: protective award maximum period doubled
- Day‑one paternity leave and unpaid parental leave fully in force
- Whistleblowing: stronger protections for reporting sexual harassment
- Bereaved partners’ paternity leave (non‑ERA): up to 52 weeks where mother or primary adopter dies in first year
- Statutory Sick Pay (SSP):
- Removal of Lower Earnings Limit
- Removal of three‑day waiting period
- Gender equality & menopause action plans (voluntary)
- Menopause guidance
- Simplified trade union recognition process
Meaning: This is the first true compliance crunch point for employers:
- SSP costs increase
- Redundancy risk increases
- “Day‑one” rights become operational, not theoretical
7 April 2026
- Establishment of the Fair Work Agency
Meaning: A new enforcement body comes into existence. While powers evolve later, regulatory scrutiny increases from this point.
October 2026
Large package of changes
Trade unions, harassment, procurement
- Addressing unfair practices in recognition processes
- Establishment of Fair Pay Agreement Adult Social Care Negotiating Body (England)
- Procurement – two‑tier code
- Tipping law tightened
- Duty to inform workers of their right to join a trade union
- Strengthened union right of access
- Employers must take “all reasonable steps” to prevent sexual harassment
- New duty not to permit third‑party harassment
- Power to define what counts as “reasonable steps”
- New protections for trade union representatives
- Expanded protections for industrial action detriments
Meaning: This is where employer liability expands materially, especially around:
- Harassment (including third parties)
- Union access to workplaces
- Documentation of preventative steps
October 2026
- Changes to employment tribunal time limits
Meaning:
Potentially longer exposure windows for claims (exact limits to be set later).
December 2026
Project Launch
- Commencement of the Mandatory Seafarers’ Charter
Meaning:
Sector‑specific; low relevance outside maritime.
January 2027 – high‑risk date
- Unfair dismissal qualifying period reduced from 2 years → 6 months
- Compensatory awards uncapped
- Fire and rehire protections take effect
Meaning: This is the single biggest risk inflection point for employers:
- Fire‑and‑rehire becomes heavily restricted
- Far more employees gain unfair dismissal rights
- Financial exposure increases sharply
2027
Wide‑ranging structural reforms
- Gender equality & menopause action plans become mandatory
- Enhanced dismissal protections for pregnant women and new mothers
- Formal definition of “reasonable steps” for harassment prevention
- Extended blacklisting protections
- New industrial relations framework
- Regulation of umbrella companies
- Changes to collective redundancy consultation thresholds
- Flexible working reforms
- Expanded bereavement leave, including pregnancy loss
- Ending exploitative zero‑hours contracts
- Electronic & workplace balloting for union recognition
Meaning: This phase reshapes:
- Workforce models
- Umbrella usage
- Flexibility assumptions
- Dismissal and restructuring strategies
Guaranteed hours and predictable working patterns
One of the highest profile areas of reform is the extension of protections around unpredictable or zero hours working, including for agency workers.
Under the revised protections temporary workers may automatically gain:
- A right to more predictable or guaranteed hours after a qualifying period
- A right to reasonable notice of shifts
- Compensation where shifts are cancelled or changed at short notice
- Shared responsibility between the agency and the hiring organisation
What this means in practice
The majority of roles we recruit for are permanent or long-term positions with structured working patterns. These roles already align well with the principles behind the new legislation.
For all of our temporary assignments our process ensures:
- Clarity of requirement
- Defined scope of responsibilities, supervision, direction and control
- Working arrangements
- Contractual frameworks for all parties
- Risk register
- Fee, margin, NI and wage transparency
Through these steps we ensure that our supply is tailored and meets stringent HMRC and FCA expectations.
Day one employment rights
From April 2026, several employment rights will apply from the first day of employment. These include:
- Statutory sick pay without qualifying period
- Day one access to paternity leave and unpaid parental leave
- Stronger employee protections around fair treatment at work
For permanent hires, these changes largely reflect existing best practice. For PAYE temporary workers, they provide greater certainty and protection, with limited operational impact for organisations that are already well prepared. The onus is on the employer, or fee payers, to ensure compliance with offering protections to workers and that the supply of staff is appropriately categorised.
Umbrella companies and supply chain standards
Umbrella companies are now formally regulated, with further approval status expected in the coming months. Recruitment agencies are expected to carry out proper due diligence on any providers they engage with.
At iGo Recruitment:
- We prioritise direct employment and permanent placements
- An umbrella company must be FCSA Accredited and Professional Passport approved, with absolute clarity of fee, remuneration and tax obligations, fully Compliant with HMRC guidelines
- If you are a contractor looking for an umbrella company that is fully compliant, holds industry accreditation or certification, pays on time, and is safe to work with, you will be pleased to hear that our scrutiny and due diligence goes the extra mile for your reassurance and peace of mind
- Where umbrellas are used, we focus on transparency, compliance, and worker protection
- We avoid hands-off models that expose clients or candidates to unnecessary risk
These changes raise standards across the industry and help ensure candidates are treated fairly.
It is important to note that there is no such thing as an “HMRC approved” umbrella company. HMRC neither approves nor regulates umbrella companies in the UK. If a provider says otherwise, they are being deceptive, and contractors should consider this a warning sign. However, HMRC does keep a list of identified tax avoidance schemes, as well as their promoters, enablers, and suppliers here.
Stronger enforcement and accountability
A new Fair Work Agency will oversee compliance with employment standards, including pay, holiday entitlement, and agency conduct. It has the power to investigate noncompliance and take enforcement action where required.
For employers, this reinforces the importance of choosing recruitment partners who understand regulated environments and operate with clear, auditable processes. For candidates, it provides reassurance that employment protections are backed by meaningful enforcement.
What this means for working with iGo Recruitment
- Temporary or interim supply is available
- Candidates benefit from clarity, structure, and appropriate protections
- Clients benefit from a low risk, compliance led recruitment partner
While hiring behaviour is evolving across the market, demand for experienced healthcare professionals remains strong. Organisations are increasingly selective about who they work with, placing greater value on quality and compliance.
Our perspective
As a business, we support the principle of strengthening employee rights and improving fairness and transparency at work. Many of the changes introduced through the Employment Rights Act address genuine issues and reflect best practice that good employers and agencies already aim to follow.
The additional cost and complexity with the new Employment Rights Act may make some employers and agencies more cautious about hiring temporary staff.
Our view is that the long-term intent of the legislation is positive, but its success will depend on how proportionately it is applied and how well employers and recruiters are supported through the transition.
Our approach
At iGo Recruitment, we have always focused on quality over volume, long-term outcomes rather than short-term fixes, and clear, compliant recruitment processes. The Employment Rights Act reinforces that approach rather than changing it, our team have been educated by our professional body, and network of experienced recruitment leaders. Our process change and reduction in Umbrella PSL has been as a direct result of re-visiting our risk assessment and advice from experienced finance and staffing experts.
Speak to us
If you are reviewing hiring plans, seek advice on how to engage temporary workers or your wider staffing supply chain arrangements in light of the Employment Rights Act, we are happy to partner and share what we are seeing across the healthcare market and to engage our network of trusted advisors where required.
For candidates seeking their next temporary, contractor or permanent positions please do register your profile with our recruitment team by submitting your CV or connecting with us online.